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Patna High Court

Suman Kumar Mandal @ Suman KumarversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The High Court set aside the refusal of anticipatory bail and granted it to the appellant, subject to conditions, under the powers conferred by Section 14‑A(2) of the SC/ST Act and Section 482(2) of the CrPC.

Summary

The appellant, Suman Kumar Mandal, was charged under several provisions of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 and the Income Tax Act for alleged assault, intimidation and defamation related to a viral video. He sought anticipatory bail, but the Special Judge under the SC/ST Act refused the prayer. The appellant contended that he had a clean record and was falsely implicated, arguing that the FIR primarily targeted another individual and that the allegations against him were vague. The State opposed the bail, emphasizing the seriousness of the offences under the SC/ST Act. The Patna High Court, applying Section 14‑A(2) of the SC/ST Act and the inherent powers of the court under Section 482(2) of the CrPC, set aside the lower court’s order and granted anticipatory bail subject to monetary and surety conditions. Consequently, the appeal was allowed.

Issues considered

  • The applicability of Section 14‑A(2) of the SC/ST (Prevention of Atrocities) Act to grant anticipatory bail.
  • Whether the allegations in the FIR sufficiently justify denial of anticipatory bail in offences punishable under the SC/ST Act.
  • The scope of the trial court’s inherent powers under Section 482(2) of the Criminal Procedure Code in granting bail.

Legislation cited

Subjects

  • anticipatory bail
  • SC/ST Act
  • scheduled caste atrocities
  • false implication
  • bail conditions
  • Criminal Procedure Code

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.981 of 2026
                         Arising Out of PS. Case No.-79 Year-2025 Thana- SC/ST District- Purnia
                 ======================================================
                 Suman Kumar Mandal @ Suman Kumar S/O Sri Kunj Bihari Mandal R/O
                 Vill.- Mehadi Ward no. 6, P.S.- Tikapatti, Dist.- Purnia.

                                                                                    ... ... Appellant/s
                                                        Versus
           1.    The State of Bihar
           2.    Pravin Ravidas S/O Late Natthan Ravidas R/O Vill.- Mehadi Ward no. 6,
                 P.S.- Tikapatti, Dist.- Purnia.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s     :        Mr. Amit Kumar Anand, Advocate
                 For the Respondent/s    :        Mr. Binay Krishna, Spl. PP
                                                  Mr. Abhishek Anand, Advocate
                                                  Ms. Kanu Priya, Adv
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   25-06-2026              1.    Heard learned counsel for the appellant and learned

                   Spl. P.P. Mr. Binay Krishna for the State and the learned counsel

                   appearing on behalf of the informant.

                            2.    This is an appeal under Section 14-A(2) of the

                   Scheduled Castes and Scheduled Tribes (Prevention of

                   Atrocities) Act, 1989 (hereinafter referred to as the “SC/ST

                   Act”) against the refusal of prayer for anticipatory bail vide

                   order dated 18.12.2025 in A.B.P. No. 67 of 2025 passed by the

                   learned District & Additional Sessions Judge-1-cum-Special

                   Judge S.C./S.T. (POA) Act, Purnea in connection with SC/ST

                   P.S. Case No. 79 of 2025 registered for the offences punishable

                   under Sections 126(2), 115(2), 308(3), 352 and 3(5) of the BNS
Patna High Court CR. APP (SJ) No.981 of 2026(2) dt.25-06-2026
                                             2/3




          as well as Sections 3(1)(r)(s) and 3(2)(v) of the SC/ST Act and

          Section 67 of the I.T. Act.

                    3.     Learned counsel for the appellant submits that the

          appellant is a person with clean antecedent and the informant

          alleges that on 11.08.2025 at 06:00AM, while he was surfing

          Facebook, he saw his obscene video and photo with a girl, next

          alleges that on 28.07.2025 Ranjeet had demanded two thousand

          silver coins and had threatened to viral the video if demand not

          met, hence the informant went to meet Ranjeet at Tikapatti

          market where appellant along with other accused were also

          present and they also abused him and demanded 2000 silver

          coins and abused in public view and also defamed him by

          publishing the same in local newspaper.

                    4.     Learned counsel for the appellant submits that the

          appellant has been falsely implicated in the instant case by the

          informant, it is next submitted that from perusal of the

          allegation as alleged in the FIR, it would manifest that thrust of

          the allegation is against Ranjeet; and as far as appellant is

          concerned, the allegation against him is general and omnibus in

          nature. It is also submitted that it does not appear probable that

          all the accused persons present at the place of occurrence in one

          go would have abused the informant by taking caste name.
              Patna High Court CR. APP (SJ) No.981 of 2026(2) dt.25-06-2026
                                                           3/3




                                  5.     Learned Spl. P.P. for the State and learned counsel

                        appearing on behalf of the informant opposes the prayer for

                        anticipatory bail of the appellant.

                                  6.     Considering the aforesaid facts, let the appellant

                        above-named, in the event of his arrest or surrender within a

                        period of six weeks from today, be released on anticipatory bail

                        on furnishing bail bonds of Rs. 5,000/- (Rupees Five Thousand)

                        with two sureties of the like amount each to the satisfaction of

                        the learned trial court where the case is pending/successor court

                        in connection with the aforesaid case, subject to the conditions

                        as laid down under Section 482 (2) of the BNSS.

                                  7.     Accordingly, the impugned order is set aside and

                        the appeal stands allowed.



                                                   (Satyavrat Verma, J)
Sumit/-

U         T


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